IRS Insights 2023: Updates, Penalty Abatement, Litigation, and Representation

Adam Fayne

Adam Fayne

Adam is a tax attorney who helps businesses and individuals with tax controversies before the Internal Revenue Service (IRS) and tax planning both domestically and internationally. He also handles a variety of white-collar criminal matters, both federal and state, particularly involving civil and criminal tax fraud, including tax evasion, money...
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Pre-recorded
180 Mins
Adam Fayne

Session 1 - 2023 IRS Representation Updates | 60 Mins

The Internal Revenue Service changes and announces new initiatives every year. This session, led by tax attorney Adam Fayne, will focus on the Internal Revenue Service’s latest initiatives and how you can prepare for a successful year representing your clients. During the session, Adam will discuss the Internal Revenue Service’s audit and collection efforts and activities, along with what you can expect in 2023 from an Internal Revenue Service that might experience its first significant budget increase in more than a decade.

Session Objectives

  • Gain valuable insights and practical tools to comprehend the Internal Revenue Service's priorities for the year 2023.
  • Explore how the IRS performed in the year 2022 and assess its achievements.
  • Understand the potential implications of a significant budget increase for the Internal Revenue Service.
  • Discover how this budget increase might influence the IRS's operations and interactions with taxpayers.
  • Equip yourself with knowledge about the IRS's evolving direction and strategies, enabling you to better serve your clients.
  • Enhance your ability to guide clients through potential changes in tax policies and procedures resulting from the IRS's focus and budget adjustments.

Session 2 - IRS Updates on Penalty Abatement Requests and Litigation | 60 Mins

The IRS asserts millions of dollars in tax penalties against taxpayers each year. This webinar by tax attorney Adam Fayne, will discuss on how to represent your client and seek abatement and removal of IRS penalties. You will learn about Reasonable Cause exceptions to penalties, the First Time Penalty Abatement procedures, various methods to request penalty abatement (e.g. in exam, appeals, post-appeals, Collection Due Process), and how to litigate penalty abatement requests when you are unsuccessful in the examination, administrative, or appellate stage. Adam will also discuss the various types of penalties that the IRS may assert against your client.

Session Objectives

This session will provide insight and tools to assist you and your clients understand what penalties may be asserted if certain actions are taken, or not taken. You will learn how to dispute penalties at the various stages of a penalty lifecycle; e.g. examination stage, appellate stage, collection stage, and refund stage. Lastly, you will learn about the ability to dispute penalties administratively and through formal litigation in Tax Court and District Court.

Session Highlights

  • The various penalties the IRS could assert against a taxpayer, including penalties related to foreign assets.
  • Contesting Penalties in Examination
  • Contesting Penalties in Appeals
  • Contesting Penalties in Collection Due Process
  • Contesting Penalties in Tax Court
  • Contesting Penalties in District Court
  • Automatic vs Discretionary Penalties
  • Reasonable Cause exception to Penalties

Session Highlights

  • IRS Audit Activity during 2022
  • IRS Collection Activity during 2022
  • IRS priorities for 2023
  • IRS Budget and what it means for your client
  • New Programs that may be beneficial to your client

Session 3 - IRS Audits and Collection | 60 Mins

The Internal Revenue Service (IRS) is no stranger to change, with new initiatives and updates unveiled year after year. As dedicated professionals in the field of tax representation, it's crucial to stay ahead of the curve, anticipate IRS actions, and ensure the best outcomes for your clients.

In this informative session, our expert speaker & tax attorney Adam Fayne will guide you through the IRS's latest initiatives and shed light on the audit and collection efforts and activities planned for the upcoming year. What makes this year particularly interesting is the potential for the IRS to receive its first substantial budget increase in over a decade, introducing new dynamics to the tax landscape.

Session Objectives

  • Gain insights into the IRS's focus areas for 2024.
  • Evaluate the IRS's performance and priorities in 2023.
  • Explore the potential implications of a significant IRS budget increase on taxpayers.

Session Highlights

  • IRS Audit Activity during 2023
  • IRS Collection Activity during 2023
  • IRS priorities for 2024
  • IRS Budget and what it means for your client
  • New Programs that may be beneficial to your client

 

Note: This is a combo of 3 Webinars (60-minute each)

Who Should Attend

  • Accountants
  • Tax Preparers
  • CFOs
  • Financial Compliance Professionals
  • Lawyers
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